UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Placer County Air Pollution Control District Rule 249

Surface Coating of Plastic Parts and Products

Prepared by: Arnold Lazarus

Reviewed by: Andrew Steckel

December, 2014
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RULE IDENTIFICATION -

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule: There have been no versions of PCAPCD Rule 249 

which have been SIP approved.

Subject of this TSD: Rule 249 - Surface Coating of Plastic Parts and 

Products

Adopted – August 8, 2013

Submitted – May 13, 2014

BACKGROUND - PCAPCD Rule 249 is a new rule that was adopted by PCAPCD

to establish requirements concerning the surface coating of plastic parts and 

products (SCPPAP). According to PCAPCD’s Staff Report associated with rule 

adoption, “The District is required to adopt volatile organic compounds (VOCs) 

standards at least as stringent as contained in the U.S. EPA “Control Techniques 

Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (CTG), (EPA 453-

R-08-03), September 2008. Rule 245, Surface Coating of Metal Parts and 

Products, was amended August 20, 2009 to meet the (CTG) requirements for 

metal parts. Adoption of this proposed new Rule 249, Surface Coating of Plastic 

Parts and Products, would meet the (CTG) requirements for plastic parts.”

1

 The 

PCAPCD is required to adopt this rule because the PCAPCD is classified as 

Severe Nonattainment for the 8-hour Ozone National Ambient Air Quality 

Standard (NAAQS). Such nonattainment areas are generally required to adopt 

local rules, like PCAPCD 249, consistent with relevant CTGs.

RULE SUMMARY - Rule 249 establishes VOC content limits and workplace 

standards for SCPPAP. It also describes related recordkeeping, reporting, and 

monitoring requirements. 

EVALUATION CRITERIA -

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency - EPA’s “Control Techniques Guidelines for Miscellaneous 

Metal and Plastic Parts Coatings” (CTG), September 2008, and other state 

and local rules for this category were used to help evaluate the RACT 

requirements of CAA §182(b)(2) and §182(f). 

 

1 PCAPCD Staff Report, “Surface Coating of Plastic Parts and Products, August 8, 2013. 
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3. SIP Relaxation - CAA §110(l) prohibits EPA from approving any SIP 

revision that would interfere with any applicable requirement concerning 

attainment and reasonable further progress (RFP) or any other applicable 

requirement of the CAA. In addition, CAA §193 prohibits the modification of 

any SIP-approved control requirement in effect before November 15, 1990, 

in a nonattainment area.

EPA EVALUATION -

1. The rule requirements and applicability are clear, and the monitoring, 

recordkeeping, reporting and other provisions sufficiently ensure that 

affected sources and regulators can evaluate and determine compliance 

with Rule 249 consistently. 

2. The relevant VOC content limits in PCAPCD Rule 249, the 2008 CTG,

South Coast Air Quality Management District’s (SCAQMD) Rule 1145, San 

Joaquin Valley Unified Air Control District’s (SJVUACD) Rule 4603 and 

Antelope Valley Air Quality Management District’s (AVAQMD) Rule 1145 

are compared in Table 1 below.

Table 1

Surface Coating of 

Plastic Parts and 

Products

VOC As Applied Limit, grams/liter (lb/gal) Less water and 

exempt compounds

Category PCAPCD 

Rule 249 CTG SCAQMD Rule 1145

SJVUAPCD

Rule 4603

AVAQMD 

Rule1145

General-One- Component 275 (2.3) 280 (2.3) 120 (1.0) 280 (2.3) 275 (2.3)

General-Multi- Components 420 (3.5) 420 (3.5) N/A 420 (3.5) 420 (3.5)

Electric Dissipating and Shockfree 800 (6.7) 800 (6.7) 360 (3.0) 800 (6.7) 360 (3.0)

Extreme Performance (2 pack) 420 (3.5) 800 (6.7) 420 (3.5) 420 (3.5) N/A

Metallic 420 (3.5) 800 (6.7) 420 (3.5) 420 (3.5) 420 (3.5)

Military Specification (1 pack) 335 (2.8) 340 (2.8) 340 (2.8) 340 (2.8) 340 (2.8)

Military Specification (2 pack) 420 (3.5) 420 (3.5) 420 (3.5) 420 (3.5) 420 (3.5)

Mold Seal 755 (6.3) 760 (6.3) 750 (6.3) 760 (6.3) 750 (6.3)
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Multi-colored 680 (5.7) 680 (5.7) 680 (5.7) 680 (5.7) 685 (5.7)

Optical 800 (6.7) 800 (6.7) 50 (0.4) 800 (6.7) 800 (6.7)

Vacuum Metalizing 800 (6.7) 800 (6.7) 800(6.7) 800 (6.7) 800 (6.7)

As shown in the table, all VOC limits in PCAPCD Rule 249 are equivalent 

or more stringent to the relevant CTG and the analogous rules in 

SJVUAPCD and, with exception of electric dissipating and shock-free

coatings which are likely to be of limited use, AVAQMD. With exception of 

this category, general one-component and optical coatings, PCAPCD Rule 

249’s VOC limits are also equivalent to the analogous limits in SCAQMD, 

which generally has the most stringent requirements in the country. As a

result, we conclude that PCAQMD Rule 249 adequately fulfils the RACT 

requirements of CAA §182(b)(2) and §182(f). 

3. We propose to determine that our approval of the submittal would comply 

with CAA §§110(l) and 193 because (1) the proposed SIP revision would 

not interfere with the on-going process for ensuring that requirements for 

RFP and attainment of the NAAQS are met, and (2) the emission limits in 

the submitted rule are more stringent than the existing SIP-approved 

control requirements that they would replace

DEFICIENCIES – We have identified no deficiencies with Rule 249

sufficient for EPA to propose less than full approval. 

EPA ACTION – The submitted Rule 249 strengthens the SIP and meets the CTG 

requirements. The rule fulfils the relevant CAA §110 and part D requirements. 

EPA recommends a full approval of Rule 249 pursuant to CAA §110(k)(3) and 

CAA §301(a).

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 

1. The 55 gallon/year exemption of non-compliant coating in paragraph 104.1 

“Low Usage of Non-Compliant Coating Materials” should be reduced to 50 

gallons/year as per the 2008 CTG.

2. We recommend reducing the VOC limits for electric dissipating and shockfree, general one-component and optical coatings consistent with the more 

stringent analogous limits in SCAQMD Rule 1145.
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REFERENCES 

1. PCAPCD Staff Report, “Surface Coating of Plastic Parts and Products, 

August 8, 2013. 

2. PCAPCD Rule 249, “Surface Coating of Plastic Parts and Products.”

3. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts 

Coatings” (CTG), September 2008. (EPA 453-R-008- 003).

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r-08-

003_misc_metal_plasticparts_coating.pdf

5. SCAQMD Rule 1145, “Plastic, Rubber, Leather and Glass Coatings,” July 

14, 2010.

6. AVAQMD Rule 1145, “Plastic, Rubber and Glass Coatings,” December 20, 

1993.

7. SJUACD Rule 4603, “Surface Coating of Metal Parts and Products, Plastic 

Parts and Products and Pleasure Crafts,” November 1, 2011.